Medicaid Applied Behavior Analysis (ABA) Rules Proposed (5160-34)

The Ohio Department of Medicaid (ODM) has proposed OAC Chapter 5160-34 that provide Medicaid coverage for Applied Behavior Analysis (ABA) services. This rule defines narrowly provider qualifications, establish documentation and service standards, and outline procedures for assessment, treatment planning, and supervision, particularly for children and youth with autism.

The Ohio Council submitted comments during the public comment period, which was open from May 13 to May 20, 2025. The comments identified several provisions that could limit service availability and create administrative barriers. The draft rules exclude community behavioral health centers (CBHCs) as eligible providers and impose credentialing requirements that exceed current licensure laws. These provisions may disqualify experienced professionals already permitted to deliver services. Prior authorization requirements and rigid diagnostic pathways may further delay care or reduce flexibility in responding to clinical needs.

Recommendations included adding CBHCs as eligible providers, recognizing clinical competency under existing licensure and training standards, and easing restrictions on when and how treatment may begin. Additional suggestions focused on improving alignment with parity laws, allowing for a range of service settings, and reducing unnecessary administrative steps that could hinder timely access to care.

The Ohio Council will continue to monitor the rulemaking process and provide updates to members as additional information becomes available.